ML23031A082
| ML23031A082 | |
| Person / Time | |
|---|---|
| Issue date: | 01/11/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2227 | |
| Download: ML23031A082 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Design-Centered BWRX-300 Subcommittee Open Session Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, January 11, 2023 Work Order No.:
NRC-2227 Pages 1-89 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 DESIGN-CENTERED BWRX-300 SUBCOMMITTEE 7
+ + + + +
8 WEDNESDAY 9
JANUARY 11, 2023 10
+ + + + +
11 The Subcommittee met via Teleconference, 12 at 2:00 p.m. EST, Joy L. Rempe, Chair, presiding.
13 14 COMMITTEE MEMBERS:
15 JOY L. REMPE, Chair 16 RONALD G. BALLINGER, Member 17 VICKI M. BIER, Member 18 CHARLES H. BROWN, JR., Member 19 VESNA B. DIMITRIJEVIC, Member 20 WALTER L. KIRCHNER, Member 21 GREGORY H. HALNON, Member 22 JOSE MARCH-LEUBA, Member 23 DAVID A. PETTI, Member 24 MATTHEW W. SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 ACRS CONSULTANTS:
1 DENNIS BLEY 2
4 DESIGNATED FEDERAL OFFICIAL:
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 C-O-N-T-E-N-T-S 1
Opening Remarks 2
Joy Rempe 4
3 Discussion of Memorandum of Understanding, 4
Memorandum of Cooperation, and Collaboration on 5
BWRX-300 (including major accomplishments, upcoming 6
activities, and joint reports) 7 Robert Taylor 7
8 Donna Williams.................
9 9
................. 36 10 Opportunity for Public Comment
......... 82 11 Discussion of Upcoming Activities, Including 12 Proprietary Schedules (Closed Session) 13 Member Discussion 14 Adjourn..................... 89 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 P-R-O-C-E-E-D-I-N-G-S 1
2:00 p.m.
2 CHAIR REMPE: Okay. My computer tells me 3
now it's 2:00 p.m. on the East Coast, so this meeting 4
will now come to order. This is a meeting of the 5
Advisory Committee on Reactor Safeguards' BWRX-300 6
Design-Centered Subcommittee.
7 I'm Joy Rempe, the chairman for this 8
meeting. Members in attendance are Ron Ballinger, 9
Vicki Bier, Charles Brown, Vesna Dimitrijevic, Jose 10 March-Leuba, Walt Kirchner, Dave Petti, Greg Halnon, 11 and Matt Sunseri. We're also being joined by our 12 consultants Dennis Bley and Stephen Schultz.
13 Mike Snodderly is the designated federal 14 official for this meeting.
15 Today the Subcommittee will discuss the 16 NRC staff's Memorandum of Understanding, Memorandum of 17 Cooperation, and Collaboration on BWRX-300 and other 18 activities with the Canadian Nuclear Safety 19 Commission.
20 The ACRS was established by statute and is 21 governed by the Federal Advisory Committee Act, or 22 FACA. The NRC implements FACA in accordance with the 23 regulations found in Title 10 of the Code of Federal 24 Regulations, Part 7. The Committee can only speak 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 through its published letter reports. We hold 1
meetings to gather information and perform preparatory 2
work for the support and deliberations at a Full 3
Committee meeting.
4 The rules for participation in all ACRS 5
meetings were announced through the Federal Register 6
on June 13th, 2019. The ACRS section of the U.S.
7 NRC's public website provides our charter, bylaws, 8
agenda, letter reports, and full transcripts of all 9
Full and Subcommittee meetings that are open including 10 t h e s l i d e s p r e s e n t e d t h e r e.
11 The agenda for this meeting was posted there.
12 Portions of this meeting will be closed to 13 protect proprietary information and information 14 provided in confidence pursuant to 5 USC 552(b)(C)(4).
15 As stated in the Federal Register notice and in the 16 public meeting notes published -- posted to our 17 website members of the public who desire to provide 18 written or oral input to the Subcommittee may do so 19 and should contact the DFO five days prior to the 20 meeting if possible.
21 The communications channel has been opened 22 to allow members of the public to monitor the open 23 portions of this meeting and the ACRS now invites 24 members of the public to use the MS Teams link so that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 it can also view slides and other discussion materials 1
during the open sessions. The MS Teams link 2
information was placed on the agenda on the ACRS 3
public web site and we did receive no written comments 4
or requests to make oral statements from members of 5
the public regarding today's session.
6 There will be an opportunity for public 7
comment during the meeting, however, and we have set 8
aside 10 minutes in the agenda for these comments from 9
members who are listening to the meeting if they 10 decide they would like to make a comment.
11 A transcript of the meeting is being kept 12 and it is requested that the speakers identify 13 themselves and speak with sufficient clarity and 14 volume so they can be readily heard. Additionally we 15 request that participants mute themselves when they 16 aren't speaking.
17 Before we begin with this meeting I want 18 to note that this topic came up during the review of 19 the BWRX-300 Topical Report, and during this meeting 20 we requested this briefing. And I want to thank the 21 staff for accommodating this request today.
22 So we'll now proceed with the meeting, and 23 I'd like to call on Rob Taylor of the Office of 24 Nuclear Reactor Regulations to begin his presentation.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 Rob?
1 MR. TAYLOR: Thank you, Joy. Good 2
afternoon, Chairman Rempe and Subcommittee members.
3 I'm Rob Taylor. I'm the Deputy Office Director for 4
New Reactors and have responsibility for the BWRX-300, 5
as well as other new and advanced reactor licensing 6
activities and our efforts in collaboration with the 7
Canadian Nuclear Safety Commission under the 8
Memorandum of Cooperation that you mentioned.
9 We're pleased to be here today to brief 10 you on an important effort related to our licensing of 11 SMRs and advanced reactors. The NRC has a bilateral 12 cooperation agreement with over 45 regulatory 13 counterparts that facilitate technical exchanges and 14 information sharing. We leverage these relationships 15 to enhance our ability to regulate the next generation 16 of reactors in the United States.
17 Today we will be discussing our 18 collaboration with our colleagues at the Canadian 19 Nuclear Safety Commission which provides a prime 20 example of the success of our international 21 cooperation on advanced reactors.
22 The NRC and CNSC have embarked on a first-23 of-a-kind effort to collaboratively perform safety 24 reviews of advanced reactor and SMR designs that are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 expected to be constructed in both countries. The 1
goal of this effort is to gain efficiencies by making 2
joint observations on advanced technologies or by 3
identifying where different regulations or 4
differing regulations may result in different 5
regulatory decisions.
6 Since signing the Memorandum of 7
Cooperation in 2019 the NRC and CNSC have participated 8
in collaborative reviews of key technical and 9
regulatory topics and produced six joint products 10 related to SMR and advanced reactor designs. This 11 cooperation has enabled us to gain valuable insights 12 into the benefits as well as complexities associated 13 with joint reviews. These lessons learned will be 14 crucial in informing how these reviews could 15 potentially be completed with multiple parties 16 involved while also ensuring that national 17 responsibilities are preserved.
18 Today we'll discuss how the Memorandum of 19 Cooperation is implemented, the successes and 20 challenges we've encountered, and talk about the 21 current projects and future plans for collaboration.
22 In particular we'll discuss recently initiated 23 projects to collaborate on specific technical topics 24 for the BWRX-300 SMR, which is the focus of this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 Subcommittee.
1 We see tremendous value in the 2
collaboration with CNSC and anticipate that the 3
groundwork that we're laying today in pre-application 4
cooperation will enable more effective license reviews 5
of the BWRX-300 and other designs in the future.
6 I'll now turn the presentation over to 7
Donna Williams who will walk us through the materials.
8 Thank you.
9 MR. SNODDERLY: You're muted, Donna.
10 MS. WILLIAMS: Apologize. I was muted 11 there.
12 I'm Donna Williams, Senior Project Manager 13 in the Office of Nuclear Reactor Regulation, with 14 responsibility for project management in the -- of the 15 CNSC-NRC MOC.
16 So the presentation today, I plan to 17 discuss how and why the cooperation with Canada was 18 initiated and how it's being implemented. We'll 19 discuss the products that have been developed, the 20 current work and how we identify projects for future 21 work.
22 Several advanced reactor and small modular 23 reactor designs are under consideration for licensing 24 in both the U.S. and Canada and the vendors are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 actively involved in pre-application activities with 1
both regulators, however different regulations, 2
guidance and practices for licensing in Canada and the 3
U.S. can negatively impact the standardization of 4
these designs. It was anticipated that if the 5
regulators were able to jointly review aspects of the 6
design, it would maximize design standardization and 7
provide review efficiencies.
8 In 2019 the NRC and CNSC signed an 9
historic Memorandum of Cooperation to provide a 10 mechanism for joint reviews of these reactors. The 11 MOC represents an important step in both countries' 12 strong commitment to be more effective, efficient, and 13 timely in the reviews of next generation technologies 14 while continuing to achieve their individual safety 15 missions.
16 The benefits of this collaboration to the 17 NRC and CNSC are effective and efficient regulation 18 and enhanced risk-informed agile decision making. The 19 MOC allows for both regulators to retain sovereignty 20 in their licensing decisions while benefiting from the 21 other's expertise and experience.
22 CHAIR REMPE: Donna, this is Joy.
23 MS. WILLIAMS: Yes?
24 CHAIR REMPE: Before you go to the next 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 slide --
1 MS. WILLIAMS: Yes.
2 CHAIR REMPE: -- I have a couple of 3
questions. I think this is a great thing to be doing, 4
but I'm curious about how you will respond to 5
stakeholders if they give you a lot of questions about 6
how do you know that you've benefitted from this 7
collaboration? Do you have metrics that you're using 8
to try and demonstrate this was a good thing to do?
9 And if so, could you elaborate on what those metrics 10 are?
11 MS. WILLIAMS: We do have specific 12 metrics, but I see Mo is on here, so he may have some 13 thoughts on --
14 MR. SHAMS: Yes, I was going to assist 15 Donna. So this is Mo Shams. Chairman Rempe, thank 16 you. If I may I can support the response to that.
17 So 100 we're aligned with your thinking 18 and the stakeholders on that, to what degree this is 19 going to benefit what we're doing. And I think it's 20 not the easiest thing to particularly measure, but 21 it's not -- also it's not the hardest for us.
22 So we have particular attributes that we 23 can point to. I think the biggest one that we can 24 point to is the ability for one regulator to leverage 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 what the other has done in the past and actually being 1
able to build on that and not particularly repeat and 2
produce duplication. And we're seeing that already as 3
we're going to tell you a little bit further down the 4
presentation on BWRX-300, particularly around the 5
fuel. So that's an area where we can point to an 6
efficiency right there.
7 Another element to it is it would probably 8
a little bit more tangible to the vendor than the 9
regulator, which is reaching more of a standardized 10 design that would work in both countries having 11 arrived to a common technical position on a certain 12 area and making the right adjustments to make that 13 design palatable for both sides. So that's an 14 intangible activity as well.
15 We try to hold ourselves very much to the 16 resources that we identify in a particular activity, 17 so we measure ourselves against that. Certainly we'll 18 try to make them as efficient as possible, but there's 19 certainly a degree of a learning curve and being able 20 to communicate on both sides the technical aspects or 21 share information.
22 So I would say it's a mixed bag of 23 specific numbers that we look at, which is resources 24 and whether or not we're meeting them and meeting our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 schedules, as well as other intangibles that we see 1
that turn value, whether it's the standardization or 2
leveraging the other regulators' prior work.
3 MEMBER MARCH-LEUBA: Hey, Mohamed, this is 4
Jose March-Leuba. This is very interesting what you 5
said. Just so I can focus on the designs, can you 6
give me an example of a design that is not the 7
standard? I mean, what do you mean by a standardized 8
design in this particular case in U.S. and Canada?
9 MR. SHAMS: Sure. Sure. I would say 10 we're interacting now with the VA BWRX-300 design.
11 We're looking to interact with other designs as well.
12 I think the benefit that goes back to the 13 vendor is if they can get both regulators to say 14 perhaps the state of safety-related equipment are the 15 same for both sides, or the number of redundancies 16 that are needed for reactivity controls, or what have 17 you, satisfy both sets of requirements on both sides 18 of the border, that's what I meant by standardizing 19 the design, or at least keeping it consistent for that 20 vendor and for both countries. That's going to 21 facilitate construction, it's going to facilitate 22 manufacturing of equipment perhaps in one country 23 versus the other. And for them in my view it 24 facilitates deployment worldwide. So that was what I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 was pointing to when I said standardizing design.
1 MEMBER MARCH-LEUBA: Yes, but say for 2
example the U.S. requires three diesel generators and 3
Canada requires only two. If I was here this time I 4
would apply for three satisfies both regulators. But 5
are you thinking that through this collaboration we 6
can agree on a two-and-a-half solution at the 7
regulatory level? And obviously there are not two-8 and-a-half diesel generators, but see what I mean?
9 MR. SHAMS: I know. Something in between.
10 Yes. I want to say you could because there may be a 11 justification that the regulator that has three can be 12 satisfied with two-and-a-half with the right 13 justification because there are other attributes in 14 the design that compensate for the difference. But to 15 your point, clearly the obvious answer would be 16 provide the three and now we've covered both. But you 17 could ultimately get in a place where you can find 18 that two-and-a-half would satisfy, even two, but you 19 still would need potentially whatever legal instrument 20 that we would need to make the two work, which is an 21 exemption or some other sort of a legal instrument.
22 MEMBER MARCH-LEUBA: Yes, the point I was 23
-- that's not the point I was trying to make --
24 MR. SHAMS: Okay.
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15 MEMBER MARCH-LEUBA: -- but the point I'm 1
thinking of now is that if the solutions have been 2
design the plant with three so that you satisfy both 3
regulations, this particular MOU 21317/162122BU is 4
wasting our time, because GE can do that on their own.
5 So I do encourage that you guys try to find a two-and-6 a-half solution whenever possible. That should be a 7
goal of the MOU, right? Otherwise, if you want to 8
pick the three, they can do it without us.
9 MR. SHAMS: And it's a great point, and I 10 agree with you. And a good bit of the guidance that 11 we hold ourselves to as a group on both sides is look 12 at the differences between the two countries and the 13 regulations and guidance and determine if they're 14 particularly -- meaningful is -- may not be the right 15 word I'd like to use, but they're that critical or 16 that important or are they being addressed in a 17 different manner perhaps? On the surface like there 18 are differences, but there are other attributes within 19 the regulatory framework that captures the same ideas.
20 So to your point, searching for that two-and-a-half 21 solution. I agree with you.
22 CHAIR REMPE: So this is Joy and I 23 appreciate this discussion. And actually the last 24 comments were, Mo, where I was thinking this might be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 a very useful exercise is understanding not only the 1
differences in the criteria and the methods to get to 2
those criteria, but the impact.
3 MR. SHAMS: Yes.
4 CHAIR REMPE: When I learned a different 5
language, I've actually learned more about my own 6
language. And I think the same thing would come from 7
this type of endeavor and it could be extrapolated to 8
other regulators in other countries. So it's not an 9
easy-to-quantify metric, but I think there's some 10 knowledge gained that should be emphasized. And 11 actually later in this -- your set of slides I wanted 12 to harp on that a bit -- point a bit more by one of 13 the other activities you've done where you looked at 14 the LMP versus the regulatory approach. Because I 15 think that that exercise could yield some more 16 benefits, and so I'm curious about that. But I think 17 knowledge gained is another important metric that 18 would help, you know, licensing future reactor sites.
19 MR. SHAMS: A hundred percent. And I 20 don't want to belabor this and take much more of your 21 time, but I couldn't express how much we're aligned in 22 the thinking on -- before we go into any comparison we 23 know it's going to be different. That's just probably 24 the more default answer than anything. It's probably 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 get out of it recognizing how the differences there 1
that are particularly critical, meaningful, and 2
practical? I like the word about that. And to what 3
degree that that impact can be mitigated to get to a 4
common solution. So we're in that -- and it's not the 5
easiest thing to get to, but certainly that's the line 6
of thinking that we're adopting here.
7 CHAIR REMPE: Thank you.
8 MR. SHAMS: Sure. Thank you.
9 Donna, back to you.
10 MS. WILLIAMS: All right. Thanks, Mo.
11 And thanks for the questions.
12 So this slide shows the structure and 13 responsibilities under the MOC. Prior to the MOC we 14 had an existing Memorandum of Understanding between 15 the NRC and CNSC that established a framework for the 16 exchange of many types of regulatory information.
17 Activities of the MOU are managed by a steering 18 committee composed of senior managers in both 19 agencies. The MOC specifically addresses advanced 20 technologies including small modular reactors.
21 A subcommittee was established consisting 22 of staff and management that are responsible for the 23 review of SMR and advanced reactor license 24 applications. Working groups of subject matter 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 experts in each country are established to cooperate 1
on the specific aspects of a design or generic topic 2
and work plans are created to guide each of the 3
projects.
4 The MOC covers several types of projects 5
including pre-licensing engagement, licensing reviews, 6
and the sharing of science and research results.
7 Projects are established to cooperate on specific 8
aspects of the design or generic topic and work plans 9
are created to guide each project by identifying the 10 objective and scope of the project, the expected 11 outputs, the work process and schedule, points of 12 contact in each agency and external organizations that 13 would be involved. The work plans ensure that both 14 agencies are aligned in the expectations up front and 15 have committed the necessary resources to perform the 16 joint review.
17 In carrying out the collaborative reviews 18 NRC and CNSC staff can hold joint meetings with 19 vendors, participate certainly in audits, issue a 20 joint set of questions to the vendor applicant, and 21 provide training on licensing processes and technical 22 issues to each other. A working group of subject 23 matter experts carries out the plan and develops joint 24 products.
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19 We developed processes for collaboration 1
to administer this first-of-a-kind cooperation such as 2
protocols, checklists, templates, and desk guides.
3 For example, a communication protocol was developed to 4
ensure that communication activities are effectively 5
coordinated and managed. The protocol also provides 6
guidance on managing sensitive information including 7
appropriate security markings.
8 To date we've successfully testing the 9
process of collaborative reviews by issuing joint 10 products that meet all of the goals of the MOC. One 11 of the goals is to collaborate on pre-application 12 activities for designs under consideration in both 13 countries. Because NRC and CNSC are both in pre-14 application engagement with X-energy, GEH, and 15 Terrestrial, we focused on specific technical topics 16 for these designs for our first projects.
17 The first report that was issued concerns 18 the reactor vessel for X-energy's advanced reactor.
19 This report documents the collaborative review of X-20 energy's approach to code identification, assessment 21 selection, and the adequacy of the regulatory analysis 22 conclusions made in the code selection.
23 We also issued a report that documents the 24 results of the collaborative assessment of the method 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 for predicting the conditions inside the containment 1
vessel following a LOCA for the GEH BWRX-300 reactor.
2 Another product is the joint report 3
concerning Terrestrial Energy USA's white paper on 4
postulated initiated events for its integral molten 5
salt reactor.
6 The second goal of the MOC is the 7
development of shared review approaches to facilitate 8
regulatory reviews. In this area we issued a joint 9
report that documents the results of a broad overview 10 of NRC and CNSC regulatory frameworks and for the a 11 specific comparison of LMP-endorsed NRC Reg Guide 12 1.233 with the CNSC approach.
13 The findings in this report will support future 14 collaborative reviews by understanding the differences 15 in our approaches for licensing new reactors.
16 A third goal of the MOC is to collaborate 17 on research and development of regulatory positions to 18 address unique or novel technical considerations for 19 advanced reactors. In this area we've issued two 20 interim reports on TRISO fuel qualification. These 21 reports address the regulatory basis for advanced 22 reactor fuel qualification in Canada and the U.S., the 23 known degradation mechanisms and failure modes for 24 TRISO fuel, and transient behavior of TRISO fuel.
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21 The issuance of these products 1
demonstrates that we can successfully perform 2
collaborative reviews and positions the NRC and CNSC 3
for future success in licensing review cooperation.
4 CHAIR REMPE: Donna. Please go back to 5
the prior slide.
6 MS. WILLIAMS: Yes.
7 CHAIR REMPE: Okay. So in one or two 8
sentences can you tell us what the biggest benefit 9
was?
10 MS. WILLIAMS: In a specific product?
11 CHAIR REMPE: And in particular I'm 12 interested in the Terrestrial postulated initiating 13 events because this is something that's always been a 14 focus of ACRS, about starting with a clean sheet of 15 paper. What did you guys learn from this interaction 16 and why was it beneficial?
17 And then on the LMP comparison report with 18 the Canadian approach, I'm interested in, bottom line, 19 why was this a good thing do? And I actually had a 20 copy of this report and I saw a lot of good ideas for 21 future activities. And what's going on about that?
22 Are you guys going to do some of those activities, 23 because I hope the answer is yes.
24 MS. WILLIAMS: Yes, and I was going to say 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 I think one of the biggest benefits of that report is 1
identifying where there are areas that we need to look 2
at more closely. And one of them was the SSC 3
classification project that we're doing now, but there 4
are several others. And we're maintaining a list of 5
possible topics for future projects using some of the 6
outputs of that report.
7 But, Mo, did you have something to add, 8
too?
9 MR. SHAMS: Sure. I think I'll build on 10 what you said. So we'll start with the LMP project.
11 Donna is spot on. We did take a good bit of insights 12 from that comparison and it did suggest that looking 13 into structure system component classification would 14 be a valuable effort, and we actually are underway on 15 that. And I believe we're aiming for earlier -- early 16 this year to put together a report that looks at our 17 process for classifying structures and components as 18 well as the Canadian. So this is a great, great 19 project and insight for us.
20 Also imbedded in that report itself there 21 was the comparisons about -- that the LMP and the --
22 sort of the dose limits that we have imbedded in our 23 regulations and how they compare to those in the 24 Canadian framework. And we also can say arrived --
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23 that there were differences, getting back to that 1
discussion we just had a couple minutes ago. We 2
ultimately arrived that there are differences between 3
these limits, but ultimately both are leading to a 4
safe licensing of these facilities. So different 5
numerics that in particularly lend themselves to a 6
difference in the level of safety that the regulations 7
assure at the end of the day. So those were good 8
insights for us from LMP.
9 We had actually follow-on discussions with 10 our Canadian counterparts on safety goals and how they 11 were developed and constructed. So there was a number 12 of great benefits that came to us from this particular 13 project.
14 For the Terrestrial one, the postulated 15 initiating event, you're 100 percent right. This was 16 an opportunity for us to exercise or at least -- not 17 just us, for the vendor to exercise and us to be able 18 to review, if you will, a clean-sheet-of-paper 19 approach looking at a technology that certainly hasn't 20 been licensed before and be able to develop initiating 21 events.
22 They did do a -- we responded that it was 23 a viable job, great job. The approach wasn't 24 particularly complete and we left that note in there 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 that more would be developed as the design has matured 1
enough, but for the level of maturity that was offered 2
to us we felt that what was offered was -- represented 3
a viable approach for identifying initiating events.
4 CHAIR REMPE: Let me focus in a little bit 5
more. Did either the U.S. or the Canadians identify 6
a type of event that -- in one country that was not 7
detected in another, or did you come up with the 8
conclusion that we both captured the same type of 9
events?
10 MR. SHAMS: We were more the latter than 11 the former. We were more near -- our finding was more 12 towards -- the approach they're using to identify 13 initiating events was viable and the ones they 14 identify are a reasonable set of events that identify 15
-- given the maturity. We didn't close the door that 16 other events would be identified as the design matures 17 further.
18 CHAIR REMPE: Okay. So far it gives you 19 a warm fuzzy, but it's not a guarantee to a vendor or 20 either regulator that if you send to one country, it's 21 going to give you the same events in the other 22 country. Just so far you've not detected anything 23 different, I guess.
24 MR. SHAMS: Yes.
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25 CHAIR REMPE: Did I summarize what I'm 1
hearing?
2 MR. SHAMS: Yes, exactly. And also 3
perhaps you can say it this way: On one hand the 4
entire approach is intended to support de-risking the 5
reviews. So at this point Terrestrial has a great 6
insight into a -- how did we envision or how do we 7
envision created postulated events and what areas 8
we'll be looking at? So they have a good sense for 9
that.
10 On the flip side of that for us, we're 11 also looking at a new technology and we're not seeing 12 major gaps, which is the point you just made. We're 13 not seeing major gaps. Perhaps there are events in 14 there that needs to be further materialized or 15 crystallized. And reliability of equipment would come 16 in there and perhaps drive events one way or the 17 other, but we didn't see major gaps that sort of 18 concern us on both sides. So those sort of two high-19 level goals in my view were reasonably accomplished in 20 that exercise.
21 CHAIR REMPE: Okay. Again this was just 22 my reading and maybe I've missed something, but when 23 I looked at the LMP document the way that the LMP will 24 do a defense-in-depth assessment after they finish 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 their analyses was described like it was a well-1 established process. And I'm not sure that that's 2
quite the situation. And you can correct me if I'm 3
confused here, Mo, but I'm just kind of wondering if 4
maybe that some insights could be gained if there was 5
a little more -- well, at least if some of the --
6 we've not exercised this approach yet really with a 7
real design. And can we explore getting some insights 8
from the Canadians and how they do it, or you think 9
that both countries are in the same situation? I'm 10 kind of getting down into the weeds to see if there 11 are some things where we know --
12 (Simultaneous speaking.)
13 MR. SHAMS: You are. You're stressing --
14 you're definitely stressing my knowledge of that.
15 (Laughter.)
16 MR. SHAMS: I would say I believe there's 17 definitely learning on both sides, that the Canadian 18 approach in this -- certainly in this area is valuable 19 for us to understand how they consider defense-in-20 depth, but as -- our approach to the LMP has been in 21 a number of ways: And number one is the frequencies 22 of events that we look at, whether it's a likely 23 event, highly unlikely events, the bands -- as you 24 would recognize when we presented this approach to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 you, the bands of events we're looking at. And then 1
also the sets of equipment and the sets of accidents 2
that we're looking at, what would be a design-basis 3
accident versus just a licensing event.
4 And then on top of that you probably have 5
seen it in the Part 53 proposed requirements is 6
specific requirements into defense-in-depth being 7
provided and describing what would that look like? So 8
no single -- particularly single system or action or 9
-- is the single sole item to be relied on.
10 So we're building through the events and 11 we're building it through the requirements for relying 12 on more than just one set of equipment or actions and 13 the like. And certainly there's room for us to learn 14 what the Canadians are doing to see how best we 15 approach that.
16 We are certainly aware that in your letter 17 to us in the past month or so there was discussion 18 about augmenting defense-in-depth. And we're looking 19 to respond in that -- in an appropriate way to 20 basically mention that what efforts we have to do 21 going forward in terms of guidance in that regard.
22 CHAIR REMPE: Yes, again I just am kind of 23 pulling the string. And I just think there's a lot of 24 good opportunities that we could learn from and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 jointly solve this all together. But anyway, I think 1
I've made my point. Thank you.
2 MR. SHAMS: Thank you.
3 MS. WILLIAMS: Okay. Yes, in addition to 4
the specific technical benefits that we've learned in 5
each of these reports, I think these first products we 6
were really testing the system. We were figuring out 7
how to work together, how to jointly perform a review 8
and issue a joint product that will pay off with these 9
benefits when we get into the actual licensing 10 reviews. This is all in pre-app and very specific 11 topics. But there were a lot of lessons learned that 12 came out of this that really made us more efficient in 13 how we can do this.
14 So that brings us to the next slide on 15 lessons learned.
So this first-of-a-kind 16 collaboration had a learning curve. In response to 17 lessons learned from early implementation of the MOC 18 we established processes and protocols to ensure that 19 the collaborative products benefit both agencies and 20 don't result in longer review times and increased 21 resources expended.
22 A challenge that we encountered was that 23 there are differences in the priority of licensing 24 projects and resources available for each regulator.
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29 To address this we identified criteria to 1
strategically select projects that will better 2
position us for success. That includes choosing 3
designs that are similar phases of submittal in each 4
agency. We also actively engaged with vendors to 5
ensure that the requests of both regulators are 6
similar enough to allow for joint review.
7 Another change to the process was to 8
expand the collaboration to include the U.K.'s Office 9
of Nuclear Regulation, who also have an interest in 10 specific projects. In September of 2021 the NRC and 11 CNSC mutually agreed to invite LNR to observe the 12 collaborative activities for TRISO fuel. We're 13 leveraging the existing bilateral arrangement that we 14 have with LNR to enable this initiative. And we plan 15 to expand on this and have LNR observe the 16 collaborative activities on BWRX-300.
17 When we began collaborative reviews we 18 anticipated that differences in licensing frameworks 19 and processes would be a challenge to developing joint 20 regulatory positions. To address this we held 21 training sessions on each other's regulatory processes 22 and we also compared the regulatory frameworks so we 23 can understand how a regulatory decision made in one 24 country can be applied in the other.
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30 One action taken to improve the 1
understanding of each other's processes was a staff 2
exchange. This formal staff exchange was included as 3
part of the collaborative review of the first GEH 4
Topical Report. This exchange was successful in 5
increasing communication and allowed CNSC and NRC to 6
better understand the different review approaches in 7
each country.
8 Because much of the work performed under 9
the MOC us withheld as proprietary or as foreign 10 government-controlled information, very little 11 information in the MOC project was made publicly 12 available initially. Recognizing that several 13 external stakeholders including other regulators are 14 interested in the collaborative activities, we made a 15 conscious effort to make reports publicly available if 16 possible. When we issue press releases, we issue 17 press releases when joint reports are issued and we've 18 create external web pages and made presentations in 19 public conferences on the activities under the MOC.
20 We also ensure that we coordinate any public 21 announcements and presentations with CNSC, and they do 22 the same with the NRC.
23 We also faced some logistical challenges 24 in sharing sensitive information, holding joint public 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 meetings, and efficiently working together to develop 1
products. These challenges were addressed to the use 2
of IT tools and alignment on new processes and 3
protocols that we use during the reviews.
4 We have discussed how the designs are 5
chosen for collaborative review and improvising 6
details on the current projects. The decision to 7
propose collaborative licensing projects is that of 8
the vendors. It's made with consideration of their 9
commercial plans in each country.
10 This slide shows the four designs that 11 have been the subject of collaboration under the MOC 12 including NuScale's SMR, X-energy's Xe-100, GE 13 Hitachi's BWRX-300, and Terrestrial Energy's integral 14 molten salt reactor. When proposing projects vendors 15 consider the timelines for submittal in each country 16 as well as the scope and depth of interactions with 17 the regulators. In agreeing to cooperation the 18 regulators consider the outcomes of products desired 19 by the vendor in each country. For example, the 20 objectives of the CNSC's vendor design review process 21 are different than those of the NRC's certification 22 and pre-licensing engagement process.
The 23 opportunities exist for leveraging information between 24 these two regulators.
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32 Even in areas where the licensing process 1
or outputs
- differ, cooperation can align on 2
fundamental scientific and engineering findings. In 3
general, a request by vendors to participate in this 4
bilateral cooperation is made because they've already 5
substantially engaged with at least one of the 6
regulators and have no plans to engage with the other 7
regulator on the same design.
8 We've established criteria to 9
strategically select licensing projects that are at 10 similar phases of submittal in each country and the 11 requests to both regulators are similar enough to 12 allow for a joint review. The decision to cooperate 13 on a licensing project is based on the following 14 factors: The extent to which the vendor is engaging 15 in meaningful pre-licensing activity with each 16 regulator, the similarity between a
vendor's 17 engagement activities in each country, the timelines 18 for engaging with each regulator, and the ability of 19 the vendor to share information about their design 20 with both regulators. These factors will determine 21 whether cooperation can occur and the usefulness of 22 that cooperation.
23 The most benefit will be gained through 24 projects in which the similarities in each country are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 well-aligned. Communication between the vendor 1
representatives in each country is also important.
2 The vendors in each country should be able to 3
collaborate effectively with each other and speak with 4
one voice.
5 Once a design is chosen for collaboration 6
the NRC and CNSC, in cooperation with the vendor, 7
identify specific technical topics for review.
8 Generally these areas are the subject of topical 9
reports or white papers that have been submitted.
10 Recognizing that the regulatory requirements will not 11 always align, collaboration will focus on the 12 technical content that ultimately satisfies both 13 countries' unique requirements.
14 The NRC and CNSC work with the vendors as 15 active participants in the collaborative process.
16 Vendors are strongly encouraged to have a point of 17 contact participating from both sides of the border to 18 represent the vendor in collaborative activities.
19 Communication protocols are established and 20 standardized at the beginning of the project. Vendors 21 must be enabled with a working understanding of how 22 both regulators conduct their pre-licensing activities 23 and what the outcomes of those processes are.
24 The NRC and CNSC work together to reach 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 alignment with the vendor on the scope of 1
collaboration and establish an understanding on how 2
this collaboration can result in both near-term and 3
long-term useful products. The regulators clearly 4
communicate the expectations with vendors that are 5
considered necessary to facilitate an efficient and 6
p r o d u c t i v e c o l l a b o r a t i o n.
7 The regulators also work to influence the 8
utilities to collaborate in the preparation of 9
licensing application. They get early alignment on 10 the scope and expected outcomes.
11 There are currently three active projects 12 under the MOC. Our collaborative work continues with 13 the TRISO fuel qualification project as the science 14 and regulatory experience evolves. As I mentioned 15 earlier we've already issued two interim reports and 16 plan to issue a final report early this year. The 17 goal of this collaboration was to establish a common 18 regulatory position on TRISO fuel qualification based 19 on existing public knowledge and to identify any 20 potential analytic or testing gaps that would need to 21 be addressed to enable TRISO use in advanced reactor 22 licensing applications.
23 It's expected that the final report will 24 enable efficiencies in the licensing process by 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 providing reactor vendors and regulators with a 1
reference-able report that documents the basis for 2
items related to fuel qualification and highlights the 3
areas where additional analysis or testing is needed 4
to support licensing.
5 We also engaged the U.K. regulator to 6
observe our activities, but there are developers in 7
all three countries proposing to use variations of 8
TRISO fuel. The benefit of a shared knowledge base on 9
TRISO goes beyond Canada, the U.S., and the U.K.
10 We're also collaborating on a project on 11 safety classification processes. The goal of this 12 project is to identify key similarities and 13 differences in a safety-significance determination 14 process, the scope of SSCs subject to the process, and 15 the outcomes, as well as the engineering design rules 16 applied to each safety class.
17 The joint report on technology inclusive 18 and risk-informed reviews for advanced reactors that 19 was developed under the MOC include a brief comparison 20 on safety classification SSCs and recommended more 21 detailed future work be done on both the safety 22 classification and application of safety 23 classification.
24 We expect that there are many similarities 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 between the regulators in these areas and confirming 1
this and identifying the differences will benefit 2
future cooperation in advanced reactor regulatory 3
activities, particularly for vendors seeking licenses 4
in other countries.
5 The working group performed reviews of two 6
pilot areas: pressure retaining components and 7
supports and reliability assurance programs. The 8
working group plans to issue an interim report and 9
results of the pilot reviews by the end of this month 10 and a final report in June.
11 Earlier this year we began collaborative 12 reviews of specific aspects of the GEH BWRX-300 small 13 modular reactor. Mike Dudek, the Branch Chief in the 14 Division of New Reactor Licensing, will present more 15 details on these projects. I'll turn it over to Mike 16 unless you have any questions.
17 MR. DUDEK: Any questions before I begin?
18 CHAIR REMPE: I'm not seeing any. Go 19 ahead.
20 MR. DUDEK: Okay. Hearing none, again my 21 name is Michael Dudek. I'm the Chief of New Reactor 22 Licensing in the Division of New and Renewed Licenses.
23 And this really where the rubber meets the road today, 24 so thanks, Donna, and thanks, Chairman Rempe and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 esteemed members of the Committee for your opportunity 1
-- the opportunity to brief this today.
2 And this really goes to the rubber meeting 3
the road on what we're doing for the current work and 4
the next steps for what we're doing on these 5
collaborative efforts with GEH and CNSC.
6 Under the Memorandum of Cooperation 7
advanced reactors and small modular reactor 8
technologies are conducting collaborative reviews.
9 The process and guidelines for collaborating on the 10 BWRX-300 have been documented in a charter that was 11 signed by the EDO in late September 2022.
12 Additionally, the staff is providing knowledge 13 transfer training to CNSC staff and they're providing 14 knowledge transfer to us. This whole initiative 15 started off with a two-week training class between the 16 two entities to understand how each other operates.
17 We have some common guidelines on the 18 ESBWR and some of the other designs from the other 19 work that we've done, but this two-work -- two-week 20 training class really got down to the nitty-gritty on 21 how each other's regulators make their regulatory 22 findings, what their regulations entail, how they make 23 their technical judgments, and just how far they go in 24 some of their reviewing. So it was very enlightening 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 to our technical staff for how they analyze, and it 1
was quite eye-opening at the end of the day.
2 So with that training class and these 3
efforts underway what is the goal? Well, the goal is 4
to conduct efficient and coordinated technical reviews 5
resulting in a common technical position. So 6
regardless of regulatory outcomes or regardless of 7
processes and procedures we have been finding common 8
ground on technical positions. Technical to technical 9
discussions on pump valves, safety structures, safety 10 systems, fuel, design have been very fruitful and very 11
-- and there's been an understanding gained across 12 borders.
13 And that's really the golden goose at the 14 end of the day, harmonization on technical items, 15 technical positions where we can agree and can find 16 those efficiencies in the BWRX-300 design, to enhance 17 the standardization. Because that's the goal at the 18 end of the day, right? I mean, I've heard it -- we've 19 heard it over and over from GEH, what if at the end of 20 the day we could submit one application for both 21 countries? Well, we're making strides in that 22 direction. We are definitely making strides in that 23 direction. It's those technical reviews and those 24 technical items where we're making the best efforts.
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39 And as always we presented some additional 1
information. Every topical report, every item that we 2
review comes before the ACRS and we have the 3
opportunity to review it. And this isn't the last 4
time that we will be in front of you talking about 5
this item, but I hope this presentation today helps 6
enhance your knowledge about where we're at where 7
we're going. And the next --
8 DR. BLEY: Can I --
9 MR. DUDEK: -- slide is going to help me 10 do that even further. Yes?
11 DR. BLEY: This is Dennis Bley.
12 MR. DUDEK: Sure.
13 DR. BLEY: I kind of followed everything 14 up until now, but I've been worrying about one -- a 15 couple of areas. When you compared what they do at 16 NRC to -- it's more a philosophy of regulation I guess 17
-- to Canada -- we'll leave the U.K. out because 18 they're pretty different I think -- are you kind of 19 similar in when you think you need independent 20 confirmatory analysis by the regulator and in areas 21 where you need experiments to back up computer 22 modeling or is there more reliance by one party of the 23 other on some of these things?
24 MR. DUDEK: So I'm going to go out on a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 limb and start the answer. Then I can turn it over to 1
Mo and Brian for perhaps additional insights.
2 But I think on the first topical report 3
that we reviewed between GEH -- it was very 4
enlightening that CNSC didn't appear to go as far with 5
the codes or utilize the codes in a similar manner as 6
the U.S. And what I mean by that is that they still 7
use the codes, they still did the calculations, but 8
they didn't -- I don't think that they went quite as 9
far as the in-depth analysis and the independence that 10 the NRC goes through with those codes and those 11 independent analysis.
12 Brian? Mo, you have any additional 13 insights on that?
14 MR. SHAMS: Yes, thank you, Mike.
15 So as we have discussed a little bit 16 earlier and we continue to point out, there is 17 differences. It's not a carbon copy approach at all, 18 but I think if we step back a little bit, we can see 19 the commonality. I think both regulators are 20 incredibly independent. They do have a commission 21 just like we do, reporting up to the commission in 22 their own way as far as their analyses and the like.
23 I probably would like to take it a little 24 bit higher than whether -- what they do specifically 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 on software validation versus not, even though it's a 1
convenient answer, but I'm seeing it across the board.
2 As we're interacting on things the independence comes 3
through, they're looking at our activities and then 4
taking that and assessing the -- in a risk-informed 5
approach what areas they wanted to look into further, 6
what areas they wanted to confirm, what reviews do 7
they want to do.
8 So I'm not particularly seeing a reduced 9
degree of independence per se or reliance on -- Dr.
10 Bley, you asked about safety features, testing for 11 safety features. I'm seeing a common theme between 12 both regulators about requiring the right data to 13 support the finding, relying on the industry and the 14 applicant to provide such information. So they have 15 a lot of language that one can map through our 16 regulations and our guidance.
17 DR. BLEY: Thanks. That's a pretty rosy 18 picture.
19 (Laughter.)
20 DR. BLEY: You're just painting a really 21 nice picture for us.
22 MR. SHAMS: Well, I think I was -- no, I'm 23 serious. No, I'm serious. I would say look at the 24 AP1000. I think that's a good example, perhaps a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
42 complete -- more complete example than the activities 1
that we're working on now. And that offers a glaring 2
example of taking what we have done and just 3
particularly looking at certain areas and ultimately 4
arriving to the conclusion very similar to ours they 5
need particularly any massive changes per se or even 6
small changes to the design. So I feel reasonably 7
comfortable that their approach and ultimately where 8
they find themselves is relatively close to where the 9
U.S. is.
10 CHAIR REMPE: So since you brought up the 11 AP1000 --
12 (Simultaneous speaking.)
13 MR. SHAMS: So, I know, yes.
14 CHAIR REMPE: -- in the U.K. regulator did 15 identify an area where the U.S. missed with respect to 16 getting data to support the assumption. I'm looking 17 for some specific examples. Did the U.S. NRC see 18 something good that the regulator in Canada is doing 19 that said -- that made you think hey, maybe we should 20 change how we do something or other, or vice versa has 21 that happened with the Canadian regulator? I guess 22 I'm kind of getting back to what metrics -- give me 23 some examples.
24 MR. SHAMS: Sure. Sure. So I'll try to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 give you examples now that we're talking AP1000, so we 1
might as well just get into that. So I think what --
2 back in the day when we were discussing it I think 3
that at the time we were having a lively debate around 4
a steel concrete composite and shield building, if 5
some of the members may recall, and the like. And 6
that was an area for them that they honed in on. They 7
looked into how that was approved by us. That was 8
another area -- a bit of a novel construction 9
approach.
10 And we went further in our own assessments 11 a n d t h e y r e l i e d o n t h a t.
12 So an area where they found us have done 13 something and they leveraged, I would point to that 14 and say that was an area they definitely had some 15 concerns with early on and we helped move them through 16 that.
17 As far as where we've benefitted, I would 18 point to something perhaps not as technical as what I 19 just provided and I would point more to how we're 20 approaching advanced reactor reviews and the pre-21 application activities that we're taking on. I think 22 a good bit of that also came from seeing the VDR 23 process for Canada and their ability to provide 24 feedback on whether a design is on the right track or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 meeting the regulations and what not.
1 So we've modeled something that ultimately 2
fits within our regulatory frames and our regulatory 3
boundaries, but it does achieve a similar goal of 4
providing input on whether a design or an idea that a 5
vendor is embracing is ultimately going to meet with 6
the regulations, with our regulations. So I'd point 7
to those activities and say there's definitely benefit 8
in our interactions over the past however many -- as 9
long as I can over the past decade-and-a-half or so.
10 CHAIR REMPE: Yeah, I know the VDR, the 11 vendor design -- whatever the R stands for -- I'm 12 drawing a blank here now.
13 MR. SHAMS: Review or something, I think 14 so.
15 CHAIR REMPE: Review. Yes.
16 MR. SHAMS: Yes.
17 CHAIR REMPE: A lot of the advanced 18 reactor components or design developers have said, 19 well, we really could use that to show we've made 20 progress. I don't know of anything we do that is 21 exactly like that other than you accept the 22 application. Are you planning to do something along 23 that lines or --
24 MR. SHAMS: So not in that format. We 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 believe what we have achieves the goal, perhaps 1
addresses the problem perhaps in a different way. So 2
we do have standard design reviews that ultimately can 3
look at any sort of -- any size, if you would, or any 4
part of a design, but we also have the -- what we're 5
sort of building truly now is the pre-application 6
review, which really could stand a small white paper 7
that's a couple of pages to just a dozen of topical 8
reports that cover broad areas.
9 So we feel like we have a flexible 10 approach that can actually achieve that. How does the 11 design meet our regulation at this point? So we have 12 a way to get there, but not -- perhaps not as 13 structured as what CNSC has.
14 CHAIR REMPE: Okay. Thanks.
15 MEMBER PETTI: Mo, I have a question. I 16 hope the internet is good. It's been going in and 17 out.
18 There was a time before I was on ACRS 19 where designers felt that it was easier to get through 20 the Canadian system than the U.S. system. And when I 21 was part of the MIT study we pushed on that and were 22 assured that that really wasn't the case, that these 23 were at very high levels in the regulatory 24 authorities.
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46 My sense was there were different 1
approaches that got you to the same place though. And 2
they asked the same questions, just maybe in a 3
different order. Is that your sense, that maybe this 4
was a misnomer that was out there about the Canadian 5
versus the U.S. regulatory approaches?
6 MR. SHAMS: Absolutely. I would align 7
myself with that thinking. They're different 8
approaches. They're asking questions in a different 9
order per se that they ultimately end up in the same 10 place. I kind of mentioned that a little bit earlier.
11 When we did the LMP comparisons we recognized that 12 there are differences in dose limits off site and the 13 like, but at the end of the day the philosophy, the 14 safety, the defense-in-depth and the like they're very 15 similar.
16 Now I think the ease versus not comes from 17 the degree of prescription in regulations, what Dr.
18 Rempe was pointing to, the VDR approach and its 19 ability to provide early feedback per se and perhaps 20 our guidance and our regs were not as structured and 21 perhaps not as well communicated to vendors as could 22 have been. So we've learned from that feedback.
23 So I agree with you, it's more a 24 perception than a reality, but we also had some role 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 to play to make sure that that perception is 1
addressed. And whatever we need to add in our 2
guidance we could, which we did facilitate that new 3
risking and a little easier start to the process 4
before you actually come and apply with a full.
5 MEMBER PETTI: Thanks.
6 MR. SHAMS: Thank you.
7 MR. DUDEK: Any additional questions?
8 (No audible response.)
9 MR. DUDEK: Hearing none --
10 DR. BLEY: I'm sorry. I got my buttons 11 confused on my computer.
12 MR. DUDEK: Yes?
13 DR. BLEY: I want to follow up on that 14 just a little bit. I was of the same mind as your and 15 Dave's discussion there. Our pre-licensing process 16 seems pretty thorough now and this -- we're seeing 17 more and more of vendors submitting topical reports 18 before their application comes in, which seems to give 19 them some of the benefits they were thinking they had 20 through the Canadian process. Can you say anything 21 more about that?
22 MR. SHAMS: Of course. Yes. I want to 23 say that over the past couple years we're seeing -- we 24 started -- it was an idea. We started it. I was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 talking with the staff about it not too long ago. The 1
road map. We were able to describing the road map for 2
non-light water reactor applicants, that there are a 3
number of ways to be able to get feedback and be able 4
to give perhaps staff formal positions. But it was a 5
concept and everybody sort of approached it in a timid 6
way.
7 I would say now we have dozens of --
8 whether it's white papers or topical reports and 9
they're being done in a systematic way. Your feedback 10 on it is incredibly valuable. We pass that along. We 11 address it as appropriate. And I think they're 12 definitely seeing that value. And I would also point 13 to the work that we're been doing on the Kairos design 14 and review. And that also presents a great example of 15 how successful it has been to use topical reports and 16 address certain areas early and how that feeds into 17 the application and stabilizes the review and supports 18 a schedule, an appropriate schedule and an aggressive 19 schedule, if you would.
20 So I think it's growing, Dr. Bley. It is 21 growing. And I can see more and more of the 22 applicants relying on that, figuring out ways. And 23 we're getting topical reports in areas that didn't 24 traditionally get topical reports. They were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 envisioned in the past to be for approving a software 1
or what -- we're looking at other than that now with 2
other areas, whether it's source term, whether it's 3
fuel qualification, whether it's regulatory 4
applicability. So I think it's working, in my view.
5 I know it's another rosy pictures, but forgive me for 6
that.
7 DR. BLEY: Yes, I kind of like -- agree 8
with your rosy picture there. I think they're not 9
getting much credit for it, at least in things that 10 end up in the press. But I think that's been pretty 11 successful so far.
12 MR. SHAMS: Thank you.
13 CHAIR REMPE: I agree it's successful in 14 some ways, but then we're also seeing multiple 15 versions of topical reports coming in from some 16 vendors. And I think -- again, I've mentioned it in 17 other meetings, but maybe we need to think about are 18 we giving them so many SSCs and iterating that it's 19 going to make the process more expensive and maybe 20 they need to have some guidance on when enough is 21 enough. So I guess don't go too far is I guess I feel 22 obligated to say on that.
23 MR. SHAMS: I think it's a fair point. I 24 think I wouldn't paint every product we receive as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 being an optimal product. I think just the line is 1
always a subjective one and different vendors approach 2
it differently. Some would go above the line to make 3
sure that they meet the line; others they want to inch 4
their way to get to that line. And that's exactly 5
what you described about multiple iteration.
6 We try to meet vendors where they are and 7
provide the feedback we can, but we're also going to 8
be honest that we're not here to grade homework, you 9
know. We're here to be able to provide the best 10 service possible to them and to the public. So 11 anyway, yes, it's definitely an evolution and I think 12 the vendor plays a role into getting their stuff here 13 on time and at quality.
14 DR. BLEY: And I'd throw in one practical 15 side. I do agree with Joy we have to be careful and 16 it probably will end up with less efficiency in some 17 areas, but then the people doing this development are 18 getting their funding in increments. They kind of 19 have to come at it in pieces, too.
20 MR. SHAMS: They certainly do. And their 21 accountability -- if we point to particular projects 22 that are funded by government per se or partially 23 funded by government, they have to meet certain 24 metrics and they have to see progress for the NRC. So 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 they do have -- they do have accountability that they 1
need to adhere to, too.
2 MR. DUDEK: Okay. If there's no 3
discussion --
4 MR. SHAMS: Mike, back to you.
5 MR. DUDEK: All right.
6 MEMBER BROWN: Yes, this is Charlie Brown.
7 I couldn't get my mic open. Apologize for that.
8 MR. SHAMS: No worries.
9 MEMBER BROWN: Yes, it is me, Charlie 10 Brown. I am on the line. Can people hear me okay?
11 MR. SHAMS: Yes, yes, we can hear you.
12 MEMBER BROWN: I'm trying to segue back to 13 a statement made in one of the earlier slides. Can't 14 remember which one. I guess I'm a little skeptical, 15 or maybe I'm the resident skeptic here as opposed to 16 all the smiling faces and shining sun that has been 17 thrown down on the discussion.
18 The object was if an applicant wants to 19 submit something, eh submits one design approach or 20 application. Does he go to both the NRC and the CNSC 21 and they both review it, or does just one review and 22 the other one accepts the review of the NRC? I'm 23 having a tough time figuring out how this becomes 24 somebody doesn't do something. If you've got two 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 people reviewing it, obviously the applicant is going 1
to have to review it with both commissions in order to 2
get it accepted.
3 So where is this commonality that -- I'll 4
use my area of I&C for an example. I mean, we get an 5
FSAR as part of an application that comes in and 6
there's a chapter that deals with the electric power 7
system as well as the I&C. And you all review that.
8 We review it. You provide an SE. We review it.
9 Whether -- if there's a topical report, we go through 10 that if necessary and we provide comments. And if you 11 note back in most of the design approvals we've done, 12 we have made comments particularly in our areas on the 13 power -- electric power and the I&C where changes have 14 been made during the application process to satisfy 15 the committee.
16 Now is there a similar committee on this; 17 I tried to figure that out from all the paperwork we 18 had, that provides a similar type approach with the 19 ACRS on the Canadian side?
20 MR. SHAMS: So that's a very specific 21 question. I don't understand the Canadian system that 22 well at that level of detail. But I know there is a 23 commission level review of their products, their 24 activities, their licensing actions. So that part is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 similar.
1 Whether or not there is an intermediate 2
level in between, an independent body like yourselves, 3
I cannot comment on that. I don't know the answer to 4
that.
5 MEMBER BROWN: The reason I asked the 6
question, I'm trying to -- just looking at my area now 7
8 MR. SHAMS: Sure.
9 MEMBER BROWN: -- all of a sudden they, 10 the applicant submits something to you guys, and they 11 come in and say, well, CNSC has already accepted this 12 and approved the design, does that mean we turn into 13 a rubber stamp and say that, no, we don't have to 14 review it because it's already been accepted by the 15 Canadian's commission?
16 MR. SHAMS: That's a great question. So, 17 if you allow me, I'll elaborate on this a little bit.
18 So the short answer to that is no. I mean, just let 19 me start by saying that. The answer to that would be 20 no. That's not what we're going to do.
21 Now, how best we can leverage that review 22 by the Canadians is really the main exercise that 23 we're doing here.
24 So there are a number of examples where, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 if a regulator has already done the review and the 1
other regulator could use it, and I pointed to AP1000 2
as a good example of that. It went through the review 3
on the U.S. side. The ACRS looked at it. Everything 4
was done.
5 So the Canadians had a great opportunity 6
to be able to leverage that and add to it what they 7
feel is appropriate to arrive to their independent 8
licensing decision. It's not a rubber stamp on their 9
end either, because they actually also have to prove 10 to their stakeholders that that design, being their 11 own independent way, that that design is safe.
12 But they have an incredible resource in 13 you as having done and looked at it. And I'll point 14 to the, you know, to I&C, the example you provided.
15 And the ACRS had approved already that I&C platform.
16 They didn't find any issues, or those have been 17 already addressed and what have you. So that presents 18 a great opportunity.
19 Now, if we are approaching issues today 20 that are -- we're at the same starting point. So, to 21 your point, there's a learning curve. Perhaps there's 22 a set of two eyes on it. Whether it's initiating 23 events, whether it's a code for a design of 24 containment or assessing containment performance, then 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 we're at a place where we're both looking at it.
1 What we aspire to in the future is having 2
the ability now to have done that work together and 3
looked at containment codes together, looked at --
4 maybe in the next round, we have the ability to be 5
able to rely on each other, construct, you know, 6
perhaps a broader team that part of it looks at 7
Chapter A versus another part is looking at Chapter B, 8
having the ability to rely on each other, review and 9
protect.
10 But, ultimately, the licensing decision is 11 independent. And that does not change. That is not 12 going to change. So, ultimately, we have to stand by 13 our decision, whether we've done the review entirely 14 independently by ourselves per se or relied on some of 15 these insights, technical insights, from our partners.
16 And the same is the other way around, whether they've 17 done an entire review on their own or relied partially 18 on some of our work. But the licensing decision is 19 independent.
20 MR. DUDEK: So let me dovetail into that 21 a little bit, Mo, in that licensing decisions and an 22 important key aspect is that -- I think a little bit 23 of your original question was, is common information 24 being submitted to both regulator. Yes. All 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 information that we have been reviewing and 1
collaborating on, GEH is submitting the same 2
information to CNSC as they're submitting us.
3 Now, we're lockstep in Canada in some 4
respects in that we're having monthly, if not weekly, 5
meetings on some of these items. So we know where 6
they're at in their review and their processes and 7
procedures, and they know where we're at associated 8
with these commonly submitted elements.
9 And that's beneficial at the end of the 10 day. So, if an interesting issue or a tough technical 11 item does come up, we're collaborating and 12 coordinating, and our technical reviewers are 13 discussing it across borders.
14 And to your point of that licensing 15 decision and whether we're able to accept something or 16 they are able to accept something from one regulator 17 to another, you know, that's the whole IAEA initiative 18 right now on harmonization,
- right, the NHSI 19 harmonization initiative where a mature regulator can 20 accept a licensing decision from another mature 21 regulator.
22 And I'm not sure we're quite there yet.
23 That's the golden goose at the end of day. And that's 24 the effort that we're talking about behind on the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 international fronts for the last six months, and we 1
will continue throughout this next year. So that's an 2
important aspect, and that's a goal to get to.
3 Mo, anything else to add?
4 MR. SHAMS: Nothing, Mike. Thank you.
5 MEMBER BROWN: Yeah, let me elaborate on 6
your, or at least try to take your comments, your 7
discussion and point it somewhat. AP1000, we 8
actually, the Committee actually challenged part of 9
the I&C design in which the vendor had to go provide 10 some additional information.
11 For example, I think this was the one 12 where we were focusing on the deterministic, well, it 13 wasn't really deterministic, processing of the overall 14 I&C system in terms of straight through, on whether it 15 was an interrupt driven, blah, blah, blah, how did you 16 make sure you could always, the thing always went from 17 point A to point B in a required time.
18 They actually came back, and we had to put 19 program limits in terms of application code that was 20 installed into that system so that it would not 21 potentially just jam it up because it was trying to 22 execute so many routines. So the other part was a 23 couple of the design details that they actually 24 cranked in based on some of those comments as well.
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58 The other big issue that we, one of the 1
big issues was the passive valves. There was a big 2
back and forth between the Committee and the staff 3
relative to the --
4 (Simultaneous speaking.)
5 MEMBER BROWN:
the triggering 6
mechanism. I won't call them one of the more 7
pejorative type of words.
8 (Simultaneous speaking.)
9 MEMBER BROWN: But there was a lot of back 10 and forth on that.
11 So it seems to me, I mean, once you all 12 have made a decision and we've adjudicated that 13 between, you know, we've made comments and if we 14 either accept it or not in the Commission rules, I'm 15 trying to figure out how you take that and you swing 16 that, how do the Canadians deal with some of the more 17 controversial type issues.
18 And bringing up AP1000 is a good point, 19 because a lot of issues came up during that review on 20 the design.
21 MR. SHAMS: Yep, yep.
22 MEMBER BROWN: And I'm not saying it was 23 on the staff, because we all agreed at the end we were 24 going forward with it.
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59 MR. SHAMS: Yep.
1 MEMBER BROWN: But that's, there was a --
2 how does the CNSC now take that and do an independent 3
review? I mean, if they, they kind of -- we're 4
building those right now. Okay.
5 MR. SHAMS: I think it's a great, great 6
great question, because it really talks to the 7
practicality of all this. None of this is static.
8 None of this is frozen in time.
9 You know, we make the best decision. You 10 give us the best feedback. We offer the Commission 11 the best recommendation we have at the time. And a 12 decision is made based on that. But there's processes 13 as we go forward to update and, you know, rectify 14 things depending on their safety significance and the 15 like. In terms of -- so that's how we maintain the 16 safety of the design if we end up finding something in 17 the end that we need to update.
18 As far as what, you know, how the 19 Canadians would benefit from that, I think it's going 20 to have to be dependent on the point of time in which 21 they're, you know, picking up our work per se and 22 relying on it. It would be -- if it's at the time 23 that we're still in dialogue with you, so there's 24 definitely a risk of, you know, you giving us some 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 feedback that leads to change things, if it's a time 1
further down on it, that's a more, you know, a reduced 2
risk if you would.
3 You know, we interact with them and others 4
as well. We interact on a periodic basis. And all 5
these issues come up.
6 You know, if we have a dialogue going on 7
AP1000, I envision such issues being brought up. If 8
we identify things clearly that's being done in 9
public, but it's more than just, you know, sort of 10 offering it in public and everybody can go read the 11 newspaper. But, no, there is our interaction with 12 them, whether it's, you know, biannually or any 13 discussion on all the different issues and topics that 14 we're, you know, interacting on.
15 We have also relationships with the 16 Canadians on oversight. You know, they had, we had 17 exchanges with the residents team or inspectors, 18 looked at AP1000 as well or other activities that 19 we're doing just for the oversight framework as a 20 whole but also for the specific technologies that they 21 had an interest in as well.
22 So these are all different mechanisms by 23 which we continue to interact and adapt through 24 changes and, you know, things that we identify along 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 the way. So I hope that gets to the point that it's 1
not frozen in time and forgotten from that point going 2
forward.
3 MEMBER BROWN: Okay. Well, thanks. Don't 4
take my queries as saying that -- you know, I'm not 5
trying to pour cold water. I think this is in the 6
positive --
7 MR. SHAMS: No.
8 MEMBER BROWN: -- area that it would be 9
useful for both countries to be able to simplify the 10 process somewhat so that we can build more of the 11 plants. I mean, it's -- the easier we can make it for 12 the applicants to be able to come up with a common, 13 common designs that satisfy both countries' 14 requirements and regulations, the better off we are in 15 the long run in terms of --
16 MR. SHAMS: Absolutely.
17 MEMBER BROWN: -- both countries. So --
18 MR. SHAMS: Absolutely, absolutely.
19 MEMBER BROWN: -- I'm just, I just don't 20 want us, the U.S., either the Commission or the 21 Committee, in my own mind to be brought up to the 22 point, well gee, it's already been accepted and go 23 forward. That's not a good end point for this 24 harmonization approach.
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62 MR. SHAMS: A hundred percent. We 1
couldn't agree more. And that is not the goal for 2
what we're doing.
3 I think there is a lot of efficiency to be 4
gained in technical, common technical positions, 5
reviews, data, software. But the licensing process 6
and the interactions with you all and the Commission, 7
that's intact. That's not being viewed as an area to, 8
you know, to change.
9 MEMBER BROWN: Okay. Thank you very much 10 for your patience with my --
11 (Laughter.)
12 MEMBER BROWN: -- my inquiries. Okay?
13 MR. SHAMS: We're grateful for the 14 questions, by the way, absolutely grateful. Thank 15 you.
16 MR. DUDEK: Absolutely. That's why we're 17 here.
18 MEMBER MARCH-LEUBA: This is Jose. Since 19 we have plenty of time, let me bring something related 20 to this. Mostly what we're doing on these 21 incorporations is not the licensing itself, but it's 22 the topical reports.
23 And it's not unusual for the NRC staff to 24 basically commission a review of a topical report 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 from, say, a national laboratory. So an expert or a 1
number of experts from a national laboratory do all 2
the technical review for a topical report. And then 3
the NRC staff does the final ten percent, comprise the 4
SER.
5 In that sense, it wouldn't be unheard of 6
if we were to commission the review of a topical 7
report to the Canadian regulators. And then we, the 8
NRC staff, do the final ten percent, of course, on 9
final SER.
10 So, since there is so much more emphasis 11 on topical reports for deciding new reactors, I think 12 there is some benefits to be gained by incorporating 13 more. If I am a regulator and I review a critical 14 heat flux correlation, why doesn't a greater number to 15 have to review from the scratch the same critical heat 16 flux correlation? I mean, if it's already been 17 reviewed, you have to reincorporate.
18 But, so there is a lot to be gained there.
19 I'm used to leaving intact the ACRS and the Commission 20 positions on roles. But 90 percent of the work is 21 done together.
22 MR. DUDEK: Well, Jose, let me take that.
23 And hopefully we can -- I'd like to parlay that into 24 the next slide just real quick, because that's where 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 I'm going to get into some of those details about how 1
we're delegating some of the work under those topical 2
reports. And we've actually expanded it to white 3
papers now as well. So, you know, the CNSC takes a 4
piece. We take a piece. And then we align on that 5
common position.
6 MR. SHAMS: Thanks, Mike. So, Jose, let 7
me answer your question. Absolutely, I think that is 8
the concept. The mechanics probably would be 9
something that we have to work out, you know, because 10 there are certainly deltas between a laboratory doing 11 it for us.
12 But your description of the concept is 13 spot on, to what degree can we use something that's 14 already been done. And that's actually, again, that 15 is what's being done today on the fuel side of things.
16 You know, we didn't quite tell you yet, and Mike is 17 going to walk through that, but when we show you what 18 we're doing for fuel, it's exactly the concept you 19 were describing.
20 We've already reviewed several topical 21 reports associated with the fuel for BWRX-300. And 22 the Canadians are having the ability now to look at 23 these reports and review them in a way that satisfies 24 their need for effect.
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65 And then ultimately after writing an SC, 1
which is in your description, would be that ten 2
percent, you know, the write-up now built on the 3
strength of what the NRC has already done in this 4
area.
5 And we're not just providing the reports 6
and the SCs that we bring. But we're actually making 7
ourselves available to meet and discuss and actually 8
provide, you know, human insights into these reviews 9
and how they were done and explanations. So I think 10 the model is quite close to what you've described.
11 And we're looking to see the same thing on 12 the other side as well. What we haven't mentioned yet 13 is BWRX is envisioned to be built in Canada ahead of 14 the U.S. by a year or so. So we can see a great deal 15 of value in seeing, you know, issues or inspections.
16 We can leverage what's being done in that regard and 17 see how we can benefit this side of the border with 18 this information.
19 MEMBER MARCH-LEUBA: Going back one step 20 further up --
21 MR. SHAMS: Sure.
22 MEMBER MARCH-LEUBA: -- for the philosophy 23 point, one thing we do, we, NRC staff. By that, I 24 mean you. I'm ACRS. One thing NRC does with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 regulatory guides is they endorse and incorporate by 1
reference, say, for example, on NEI position.
2 MR. SHAMS: Sure.
3 MEMBER MARCH-LEUBA: I don't think we are 4
going that far. I think that to keep everybody happy 5
it would be best if we do the topical report 6
commissioning a national laboratory model in which 7
they do 90 percent and we do 10 percent. So I just 8
wanted to bring that to your attention. I mean, when 9
we say incorporating by reference, people start 10 getting cold feet, I think.
11 MR. SHAMS: It's a great idea. And we'll 12 definitely reflect on it and see. And as I say, we'll 13 find the right mechanics for it. But the idea, we 14 absolutely share the same vision on that.
15 DR. BLEY: This is Dennis again. Michael, 16 you tossed out white papers. And I guess if you're 17 not planning to say more about it, please say some 18 more now, because those aren't something that you 19 actually approve. What's the role of white papers in 20 all of these processes we're talking about?
21 MR. DUDEK: So I'll answer that in just a 22 minute. But I'd like to go back to the previous slide 23 first and answer your first question with some 24 additional information on it. Can you go back one 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 slide?
1 So, Member Bley, just to answer your 2
question on some of the codes and what we've done and 3
how they apply to the proposed regulators, I would 4
refer you to that first joint report on the 5
containment evaluation method. And I just sent the 6
joint report to Mike Snodderly and the ML number is 7
22031A279. And that ML number is for that joint 8
report. And it gives some additional details on that 9
code piece.
10 But colloquially, let's start -- and to 11 your white paper discussion, let's discuss what work 12 is actually being done right now. And this is 13 colloquially called our five-member or five-topic 14 discussions, CNSC, NRC, TVA, OPG, and SaskPower. So 15 essentially it's now six with the addition of 16 SaskPower.
17 And as Mo very graciously said, OPG is a 18 step ahead. And they will be building a year ahead of 19 us. We will be learning a lot about their processes 20 and procedures and how this is going to go forward.
21 And SaskPower is now a new member to our five-party 22 discussions, as they may be purchasing the GE Hitachi 23 as well. So next slide.
24 So what are we doing? And it goes to that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 white paper and that topical report discussion. And 1
that's to say that we have three work plans that are 2
currently underway, you know, under the structure of, 3
you know, the MOC and the charter that was signed by 4
the EDO in 2022. We have an annex to that charter, 5
which is really the work plans themselves. What work 6
is actually going to be done? What are we actually 7
doing? And what are we actually collaborating on?
8 And we've decided to collaborate on three 9
items, three technical items, that we've been, that 10 the three entities, us, CNSC, and GEH, have aligned on 11 that would be of benefit to discuss. And it's really 12 those advanced construction techniques, the safety 13 strategy white paper, and a fuel verification and 14 validation report that we're, that both countries are 15 looking at.
16 So I'm going to describe a little bit more 17 about each one of them if that's okay.
18 First and
- foremost, the advanced 19 construction technique project, so NRC and CNSC are 20 currently reviewing, each reviewing the white paper 21 that was submitted to both SCs by GEH. And this is 22 really, you know, goes to the bottom line of steel 23 plate composite containment vessel construction for 24 the reactor building structural design.
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69 This white paper is, describes the use of 1
what they call steel bricks. Now, these steel bricks 2
will be used for the construction of most walls and 3
floor for the BWRX-300 integrated reactor building.
4 And these steel bricks will be filled with cement and 5
with steel tie rods and will be a structural element 6
for the containment and reactor building structures.
7 New and novel designs, something that the 8
U.S. at least hasn't seen before. I think it's been 9
used in a couple other entities. But, you know, this 10 is new to at least me. And I'm learning a lot about 11 it.
12 So they did submit this white paper to us.
13 We have been reviewing it since October 14, 2022. We 14 have had a public meeting on it. And that was in 15 November 12, 2022. We had a joint public meeting on 16 it between the NRC, CNSC, and GEH.
17 And now we're working to put that joint 18 report and put that meeting summary and those joint 19 efforts and those joint learnings of what we've done 20 over the last, you know, three to four or five months 21 together. And we should see something come together 22 on that by March, the end of March of 2023.
23 Any questions on steel bricks before we 24 move on?
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70 MEMBER KIRCHNER: Mike, this is Walt 1
Kirchner. Happy New Year first, and then, also Mo.
2 Just, Mike, you were, weren't you the 3
lead, your staff the lead on the NuScale steel plate 4
composite PR review?
5 MR. DUDEK: It's not, the steel plate 6
composite isn't quite what these steel bricks is. And 7
what I mean by that, this steel brick technology is 8
almost two steel plates put together with tie rods, 9
and then you fill it with concrete as part of the 10 structural element. So it's a little bit different 11 than what the NuScale design entailed.
12 (Simultaneous speaking.)
13 MEMBER KIRCHNER: Without getting into 14 proprietary details, the basic concept is the same.
15 MR. SHAMS: It is. And it's the same 16 concept that AP1000 used as well. So I'm --
17 MEMBER KIRCHNER: Right.
18 MR. SHAMS: -- I'm with you. And I know 19 you remember in those days, they came in and presented 20 to you on what AP1000 was and was not. So, yes, you 21 know, it's not particularly that different. But there 22 are proprietary elements that are somewhat different, 23 yes.
24 MEMBER KIRCHNER: Of course, but back in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 that time, Mo, since you brought it up, this is Dennis 1
again --
2 MR. SHAMS: Yep.
3 MEMBER KIRCHNER: -- there were no 4
consensus standards on steel plate composite 5
constructions. There are now. So I assume that's 6
having, feed into --
7 MR. SHAMS: It is, yeah, it is definitely 8
helping quite a bit to have -- do you remember --
9 you're right. The dialogue back then was the data 10 that we've used and the testing that was assembled at 11 the time. I think we're in a better place now.
12 But there's also -- and Mike, you know, 13 I'm sure will have the ability to describe. There is 14 a testing program that's taking place for that 15 particular design that BWRX-300 is adopting. And 16 they're working with BUE and -- in particular to do 17 the sum validation of their data and their models.
18 So, yes, it's both. There's data as well as better 19 foundation in terms of codes.
20 MEMBER KIRCHNER: Okay. Thanks.
21 MR. DUDEK: Yeah, and some of those 22 initial tests are being done out at the University of 23 Purdue. And we're slated to go out and see some of 24 those additional steel brick tests later this year as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 part of the -- project.
1 MEMBER KIRCHNER: Mike, this is Walt 2
again. That brings up an interesting thing.
3 I'm not familiar with how the Canadians 4
deal with ANSI and other American standards. Probably 5
in this topical area we're talking about civil and 6
also ASME.
7 You mentioned earlier your joint work on 8
the pressure vessel for the X-energy. You know, 9
nominally at least on the U.S. side, one would look to 10 ASME code case or such to cover a novel high 11 temperature design like that.
12 How does it work with the Canadians in 13 terms of standards? Do they rely a lot on the ASME 14 boiler and pressure vessel code? That would seem to 15 be, you know, the go-to place for that pressure vessel 16 work for X-energy.
17 MR. SHAMS: I can take that, Mike.
18 They do, Dr. Kirchner. Yeah, absolutely, 19 they do. We do have a common utility, if you would, 20 for the ASME code. I believe it's, you know, it's 21 integrated in their thinking and approach for building 22 nuclear plants.
23 And when we did do a joint effort on the 24 X-energy vessel construction code, we had a common 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 view that what was presented was viable. So that 1
gives you an example of them, you know, adopting an 2
ASME code revision or a section per se. So, yes, 3
they're definitely embracing that code.
4 MEMBER KIRCHNER: Does the same hold for 5
IEEE as well? Just excuse my unfamiliarity with the 6
Canadian licensing processes.
7 MR. SHAMS: Sure.
8 MEMBER KIRCHNER: Do they look generally 9
to IEEE for the electrical and digital standard base?
10 MR. SHAMS: That's a little bit deeper 11 than I know about their regulatory framework. So 12 don't know the answer to that.
13 But I would like to offer a more general 14 answer, as I think they have a lot of, they see a lot 15 of value in American codes and standards per se. But 16 they're also well integrated internationally. So 17 you'll see international products, you know, that 18 they're using as well. But I don't know the answer to 19 the IEEE specifically.
20 CHAIR REMPE: Let's go on to your second 21 bullet because of time. We're using up the allocated 22 time rapidly. Thank you.
23 MR. DUDEK: Absolutely. And this second 24 work plan is what we colloquially call the safety 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
74 strategy. And this is the NRC and CNSC are currently 1
reviewing a white paper entitled safety strategy. And 2
it's for that BWRX-300.
3 So the white paper was submitted to the 4
NRC in early December, December 6, 2022. And it 5
really looks to incorporate the selective guidance 6
from the IAEA's safety standards for specific safety 7
requirements in SSR2/1, Revision 1.
8 GEH is not requesting specific regulatory 9
endorsement of the IAEA standard by either the NRC or 10 CNSC. However, the objective of the safety strategy 11 is to establish the design and a high level strategy 12 of safety when using defense in depth concepts between 13 the two countries associated with the IAEA standards.
14 GEH believes that this is accomplished 15 through the incorporation of the design requirements 16 through selective guidance. And it also believes that 17 it's consistent with the current NRC and CNSC 18 regulatory requirements.
19 So we're really looking on how does the 20 NRC do business, how does CNSC do business, and can we 21 parlay our understanding for that associated with this 22 IAEA standard.
23 We've had an initial public, joint public 24 meeting in December 14th. We have been providing, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 meeting regularly with CNSC and providing that 1
preliminary feedback to GEH. We're working on a 2
meeting summary and a meeting feedback. And we're 3
taking a look at, a comprehensive look at this topic 4
5 (Audio interference.)
6 CHAIR REMPE: -- GEH. Yet the CNSC and 7
the NRC would say if you follow this IAEA standards 8
it's likely you're going to meet our regulatory 9
requirements. Is that what they'd like to have you 10 say and you're trying to evaluate it for something 11 that there would be a gap by just following the IAEA 12 safety standards?
13 MR. DUDEK: Yeah, I think very simply 14 we're looking at that gap.
15 CHAIR REMPE: Okay. And then could I have 16 you send a copy of this white paper to Mike so that it 17 could be provided to the ACRS members and slides from 18 that meeting?
19 MR. DUDEK: Sure. I think we can do that.
20 I'll take that as a note.
21 CHAIR REMPE: Okay. Thank you.
22 MR. DUDEK: Mo, anything to add?
23 MR. SHAMS: No, Mike, you covered it.
24 Thank you.
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76 DR. SCHULTZ: Mike, this is Steve Schultz.
1 Just a question on the IAEA standard and work here.
2 Over the past two years at least, the IAEA 3
has been looking at the revision of the, of the 4
Revision 1 standard going forward to apply to new 5
reactor designs. And has that been something that the 6
GEH folks have incorporated into their reviews here 7
and to this strategy?
8 MR. DUDEK: I think it's their proposal at 9
this time. I'm not sure that they've actually 10 incorporated it. They've submitted a white paper 11 floating this idea to us on how this would work and 12 whether we can get our arms around it. And then I 13 think they have a topical report or I believe they 14 have a topical report planned for later this year 15 that's going to flesh this out even further.
16 DR. SCHULTZ: Good. Thank you.
17 And I did note in looking at the 18 information we have been provided on the overall 19 licensing approach for CNSC and NRC that for the CNSC, 20 their defense in depth approach is almost readily 21 adapted from the IAEA approach, though I'd be 22 interested in seeing that work that you're going to 23 forward to Mike so --
24 MR. DUDEK: Sure.
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77 DR. SCHULTZ: -- we can review that.
1 Thank you.
2 MR. DUDEK: Sure. I will forward what I 3
can. And I'll round with Mo and Brian on what I can 4
find. Okay.
5 DR. SCHULTZ: Thank you.
6 MR. DUDEK: Absolutely. So, without any 7
further discussion on that, we'll move on to the third 8
topic of the, the third work plans. And that's really 9
the fuel verification and validation, you know, and 10 this GNF2 fuel that the BWRX-300 design is proposing 11 to utilize. But we've seen that same fuel as part of 12 the ESBWR. So the NRC is very familiar with this 13 design.
14 And we've had several public meetings with 15 CNSC over the last three months to try to bring 16 understanding and commonalities
- across, and 17 harmonization across borders of what we've seen and 18 what we've known and trying to brief and get CNSC 19 comfortable with reviewing that information that GEH 20 is going to send to both of us. So it's more of a 21 mentor-mentee of mature regulators at that point for 22 at least this topic.
23 Mo, anything to add on that?
24 MR. SHAMS: No, Mike. I would, you know, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 the only item I point to is this is really again the 1
prime example of how are we leveraging this activity 2
to gain efficiency, to gain mileage, if you would.
3 It's by things like this, what we've done 4
versus what they have done and how we can share that 5
knowledge and help the other regulator move forward 6
quicker, faster and with a foundation of great work 7
that's done by the other regulator. So this is a 8
prime example of that.
9 DR. BLEY: A quick question from Dennis.
10 MR. SHAMS: Sure.
11 DR. BLEY: I've heard the phrase another 12 mature regulator many, many times --
13 MR. SHAMS: Yes.
14 DR. BLEY: -- which on the surface makes 15 sense. To get specifics, into specifics, it might be 16 hard to pin down. Is IAEA, are they declaring who are 17 mature regulators? Are you guys? Where is that -- is 18 that really a big deal here, or is that just language 19 that's floating through?
20 MR. SHAMS: So I wouldn't say it's a big 21 deal between us and the Canadian regulator, because 22 we're both, I would say fit the category of mature 23 regulators. I think it's -- in our vision, you know, 24 early on, it continues to be is we start with folks 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 that we have a great deal of commonalities to start 1
building a model that works and we can identify where 2
we can benefit from each other and when we cannot.
3 So I wouldn't characterize either of us as 4
an immature regulator. But does that exist? Yeah.
5 Certainly, you know, developing nations, those that 6
are early on in their journey with these reactors and 7
these technologies, we would probably say that they 8
still need a bit to gain to get to a mature regulator.
9 And that would be the group that would be looked at as 10 not particularly a mature regulator.
11 DR. BLEY: So, as this grows and goes 12 forward, with you and the Canadians and maybe other 13 countries coming in I guess it's this group of 14 regulators who decide who gets to come into the club 15 in the future.
16 (Simultaneous speaking.)
17 MR. DUDEK: I think it's more in depth 18 than that. I think the IAEA forum under the SMR 19 regulators forum, which we're discussing and defining 20 some of these terms, there's over 30-plus countries 21 that are in those discussions and aligning on, you 22 know, who is a developing country and who is a mature 23 regulator.
24 And it's pretty clear in those 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 discussions. You know, if you license multiple 1
reactors, if you have a good operating fleet, and you 2
have well established processes and regulatory 3
procedures, then I think for all intents and purposes 4
you're a mature regulator in at least the IAEA's view 5
and how we're defining and how you'll see some of 6
these reports coming out for those --
7 DR. BLEY: Okay. Thanks, Michael. That's 8
9 MR. DUDEK: -- for those countries.
10 DR. BLEY: That's what I was looking for.
11 And I guess IAEA is kind of the lead on this, if there 12 is such a thing as a lead.
13 MR. DUDEK: Yes. Okay. Next slide, so 14 bringing up the tail end here on next steps if we can.
15 And the next steps are really, you know, 16 the U.S.
and Canada are routinely exchanging 17 information. As I said, these are monthly, daily, and 18 weekly activities.
19 And it's anticipated that pre-application 20 engagement to identify additional potential projects 21 and technical areas are, you know, highly sought 22 after. And we're discussing them on a routine basis 23 between our senior managers and our staff to come up 24 with these collaborative reviews and these 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
81 collaborative ideas.
1 And really the thanks is to GEH for, you 2
know, really coming to the table and giving us this 3
opportunity on these topics and really sending some 4
challenging topics in front of us that we can both 5
align on and interact on. And we want to be 6
successful at the end of the day. And we want to 7
provide them some benefits. So, you know, all of this 8
is in the back of our minds.
9 So, while the focus of current projects is 10 on pre-application and interactions, you know, really 11 at the end of the day, you know, we're cooperating and 12 collaborating with an important entity to our north to 13 review on specific sections and topics. And 14 hopefully, you know, that golden goose at the end of 15 the day is harmonization and CNSC's and NRC's goal of 16 conducting joint reviews and these joint activities on 17 topics and activities jointly.
18 So, with that being said, I'll turn it 19 over to, back to either you, Chairman Rempe, or Mo and 20 Brian for any additional thoughts that you have.
21 CHAIR REMPE: Okay. So this is Joy. Mo 22 or others on the staff, do you have any final 23 comments?
24 MR. SHAMS: No, thank you. No, the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 questions have been incredibly thoughtful. And I hope 1
that we were able to respond to your inquiries and 2
will provide the information you requested. But other 3
than that, no, back to you.
4 CHAIR REMPE: You've done a great job. I 5
found this presentation very helpful.
6 I want to remind members and consultants 7
that there is going to be a closed session. But if 8
there's any other questions you want to ask in the 9
open session, this is the time to do that. And then 10 we'll open up the line for public comments. I see 11 your hand up, Dennis.
12 DR. BLEY: Yeah, just a quick one in an 13 area that I guess I'm not too concerned about. But 14 Congress has passed the laws that establish NRC as the 15 nuclear regulator for the United States. Is there any 16 legal issues that are troublesome here with making 17 these kind of cooperations work?
18 MR. SHAMS: We haven't encountered any.
19 And as long as it remains in a place that doesn't 20 particularly impact our sovereignty and our ability to 21 make our licensing decisions independently, we see 22 this as another merging of our interactions that we 23 have been doing for a while, whether it's bilateral or 24 multilateral through IAEA, other organizations. So, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 no, our legal advisers did not find issues with what 1
we've been doing.
2 DR. BLEY: Okay. Thanks a lot. And 3
thanks for the --
4 MR. SHAMS: Sure.
5 CHAIR REMPE: Charlie, I saw your hand up 6
next.
7 MEMBER BROWN: Yeah, thanks. I wanted to 8
-- the two white papers, which are pretty high level 9
type documents when you get right down to it, 10 strategies for doing various things, as well as the 11 details on the construction techniques item, the -- I 12 wanted to emphasize a little bit of Jose's comment 13 relative to the topical reports. That's where the 14 rubber hits the road in the details, the piece parts 15 that you put these plants together with in most 16 circumstances.
17 And I know in my area we've, there's been 18 a couple of topical reports that have been reviewed, 19 and then they have been used by other applicants. And 20 they've flown through the review process with barely 21 a wink and a nod. I mean, they were agreed to once.
22 And they were accepted by the next applicant, and away 23 we went. And they worked very, very well.
24 So the topical reports are, I just wanted 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 to emphasize what Jose said, that those are an 1
important linchpin when we're getting down to the 2
details about what the plants and what the applicants 3
are going to design the specific systems utilizing.
4 That was my only thought. So don't lose sight of 5
that.
6 MR. SHAMS: No, no, we're not. And I 7
thank you for the feedback on that. And we want to --
8 I don't know if we answered the question as crisply as 9
we could have been.
10 The white papers are not replacing topical 11 reports by no mean. They serve a different purpose.
12 They serve a purpose of are we on the right track per 13 se and what elements are missing versus not. So 14 that's, the purpose they kind of offer is an 15 opportunity to provide feedback.
16 A topical report is a topical report.
17 It's a licensing tool. It gets your review. It gets 18 our SC and a staff position is preserved and can be 19 incorporated by reference. So they serve different 20 purposes.
21 CHAIR REMPE: Okay. And then I saw Greg's 22 hand up.
23 MEMBER HALNON: Yeah, thanks, Joy. If 24 you've covered, I got two questions, and if you've 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 covered them already, I apologize.
1 MR. SHAMS: Sure.
2 MEMBER HALNON: One of them is, do you 3
ever see a situation where you might endorse a 4
Canadian standard so that there's only one effort by 5
the licensee to, or the applicant to establish their 6
documents?
7 MR. SHAMS: I would probably say certainly 8
there's no reason for us not to. I'd say I would 9
point more to more international thing, like an ISO 10 9000 per se. So that's more of an example of what you 11 pointed to. That would be an opportunity for us to 12 endorse something that licensees can use on this side 13 of the border versus the other. But conceptually, 14 there's no reason not to. Yes, if we find something 15 in there that supports us and our reviews, we would do 16 it, yes.
17 MEMBER HALNON: Okay. Second question, do 18 you ever -- well, when is it not appropriate? Do you 19 foresee any circumstance or situation where you would, 20 if an applicant came in and said we want a joint 21 review, you would say no, thank you?
22 MR. SHAMS: That's a great question. I 23 didn't mean to -- but it's a tough question. I would 24 say that the characteristics and the aspects that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 Donna went through early on is to make this as 1
efficiently as possible.
2 You know, I'll start by saying we're open 3
for business. If anybody -- you know, it's a public 4
service operation. So, if anybody is submitting an 5
application to us, we certainly have a place for them.
6 Whether or not they did the right priorities or their 7
budget, of course, that plays a factor in, you know, 8
how quickly we can get to it.
9 Now, in terms of a joint collaborative 10 effort on a review, that would have to be impacted by 11 a number of factors, you know, how well is that 12 application oriented for the two regulators to 13 collaborate, is one far ahead of the other, you know, 14 do we have similar design or are there differences.
15 So those are the factors, what's on our 16 plate versus what's on their plate, is it going to be 17 built in both countries versus both in one but not in 18 the other. So those would be the criteria and the 19 attributes that we would use to decide, you know, the 20 priority of that application.
21 MEMBER HALNON: Okay. Thanks, Mo.
22 MR. SHAMS: Sure.
23 CHAIR REMPE: So I know you were going 24 from the phone to the computer, Greg. And I believe 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 it's slide 8. It's where Donna went through those 1
characteristics and criteria that emphasize which ones 2
might be viewed more favorably to use.
3 At this point, I'd like to open up the 4
line for public comments. If you are online, you 5
should raise your hand and, or do a star 6. I don't 6
see -- I saw a hand, but it disappeared. Is there 7
anyone who wants to make a public comment? Okay. I 8
think I've given us enough time.
9 And the phone lines, if you wanted to make 10 a comment, you I believe hit star 6. And that unmutes 11 you. And that would allow you to make a comment. So 12 I'll give you a couple of seconds longer.
13 And not hearing anything, then it's time 14 for us to switch and go to the non-public invitation.
15 And again, I want to thank the staff for the great 16 presentations and their willingness to brief us.
17 I believe, but, Mo, perhaps you or others 18 could confirm this, but I believe the CNSC folks would 19 be allowed to be in this closed session. Is that 20 true? I'm not hearing --
21 MR. SHAMS: No, I'm, yeah, I'm thinking 22 the answer through.
23 CHAIR REMPE: Okay.
24 MR. SHAMS: Yeah. I honestly don't know 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 the answer to that. I would have to confer with my 1
staff on that. I don't know the answer to that. I 2
know --
3 CHAIR REMPE: Okay.
4 MR. SHAMS: -- I forwarded them the link 5
this morning. I don't know if they have the link for 6
the closed session.
7 CHAIR REMPE: Okay.
8 MS. WILLIAMS: Yeah, the information I 9
think we were planning to discuss in the closed 10 session is the subjective meetings that we've had with 11 CNSC. So I don't see a reason why they couldn't.
12 MR. SHAMS: So there's your response.
13 Yeah, ordinarily, you know, we would have to be 14 careful with what's being discussed, whether it's 15 proprietary or not. But this is their information.
16 They are partners with us in this information. So it 17 would be appropriate for them to attend.
18 CHAIR REMPE: So I will trust you to 19 forward that to them.
20 And then let's take -- I know we're 21 running a little bit late. But why don't we take a 22 five-minute break, because it takes a while to confirm 23 everybody is really here that should be here? So 24 let's restart at 3:50 p.m. Does that sound good? And 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
89 thank you.
1 MR. SHAMS: Thank you.
2 CHAIR REMPE: Okay.
3 MR. SHAMS: Appreciate it.
4 CHAIR REMPE: Thanks again.
5 (Whereupon, the above-entitled matter went 6
off the record at 3:45 p.m.)
7 8
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CNSC - U.S. NRC Cooperation on Advanced Reactor Technologies and Small Modular Reactors January 11, 2023
Outline
- Introduction
- Memorandum of Cooperation process
- First products
- Current work
- Future projects
Introduction
- Memorandum of Cooperation signed in 2019 to collaborate on reviews of designs submitted for review in the U.S. and Canada
- Goal - Collaborate on ART-SMR design reviews and share experience
- Effective and efficient regulation
- Risk-informed agile decision-making 3
Implementation of the MOC MOU Steering Committee MOC ART-SMR Subcommittee Work plans Working groups/ subject matter experts
Scope of Memorandum of Cooperation (MOC)
Scope of projects
- Pre-licensing engagement
- Licensing reviews
- Science and research Development of work plans Processes for collaboration
Pre-licensing Engagement X-energy - Xe100 reactor pressure vessel construction code assessment
- GEH-BWRX-300 Containment Evaluation Method
- Terrestrial - postulated initiating events Joint NRC/CNSC Products Unique Technical Considerations TRISO fuel qualification Review Approaches Report Comparting the U.S. LMP with the Canadian Approach
Expansion to include UK/ONR Lessons Learned and Improvements to the Collaboration Process Staff exchanges Upgrades to collaboration tools Strengthened communication to external stakeholders
Project Selection
- Request by vendors
- Criteria
- The extent to which the vendor is engaging in meaningful pre-licensing activity with each regulator
- The similarity between the vendors engagement activities in each country
- The timelines for engaging with each regulator
- The ability of the vendor to share information about their design with both regulators
Current Work Collaborative work plans underway GEH BWRX-300 TRISO Fuel Qualification Safety Classification of Structures, Systems and Components
Joint Review of GE Hitachis BWRX-300
- Goal: Efficient and coordinated reviews resulting in common technical positions
- To date, NRC and CNSC have successfully collaborated and issued a joint report on BWRX-300 containment evaluation method.
CNSC-NRC MOC BWRX-300 Current Projects BWRX-300: Advanced construction techniques. The NRC and CNSC staff are reviewing a white paper on BWRX-300 Steel-Plate Composite (SC) Containment Vessel (SCCV) and Reactor Building Structural Design BWRX-300: Safety Strategy. The NRC and CNSC staff are reviewing a white paper on the Safety Strategy for BWRX-300.
The Safety Strategy incorporates selected guidance from the IAEA Safety Standards Specific Safety Requirements No. SSR-2/1, Revision 1, Safety of Nuclear Power Plants: Design.
BWRX-300: fuel verification and validation. CNSC is leveraging previous USNRC reviews of the GNF2 fuel product in the CNSCs review of OPGs construction license application.
Next Steps
- Work with vendors and utilities to identify specific technical issues and perform joint reviews of topical reports and white papers in the pre-application phase
- Cooperate on the review of specific sections or topics in licensing applications.
12